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Western Digital Technologies v. Godo Kaisha IP Bridge 1

Docket IPR2025-00701, Patent Trial and Appeal Board (Mar. 6, 2025)
Case TypeInter Partes Review
Patent10367138
Patent Owner Godo Kaisha IP Bridge 1
Petitioner Western Digital Technologies
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3 Notice Power of Attorney: Patent Owners Power of Attorney

Document IPR2025-00701, No. 3 Notice Power of Attorney - Patent Owners Power of Attorney (P.T.A.B. Mar. 26, 2025)
In accordance with 37 C.F.R. § 42.10(b), Patent Owner GODO KAISHA IP BRIDGE 1 hereby appoints: Gerald B. Hrycyszyn (Registration No. 50,474) Jie Xiang (Registration No. 74,068) Thomas A. Franklin (Registration No. 63,456) Richard F. Giunta (Registration No. 36,149) Adam R. Wichman (Registration No. 43,988) and all practitioners associated with USPTO Customer Number 23628 of Wolf, Greenfield & Sacks, P.C., 600 Atlantic Avenue, Boston, Massachusetts 02210, United States of America, as its attorneys to transact all business before the United States Patent and Trademark Office associated with the Inter Partes Review of U.S. Patent No. 10,367,138.
I have authority to sign this document on behalf of GODO KAISHA IP
I certify that on March 26, 2025, a copy of the foregoing document, including any exhibits filed therewith, is being served via electronic mail, as previously consented to by Petitioner, upon the following: Michelle E. Armond Douglas R. Wilson Josepher Li Monica Arnold Yue Han
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4 Notice Mandatory Notice: Patent Owners Mandatory Notices

Document IPR2025-00701, No. 4 Notice Mandatory Notice - Patent Owners Mandatory Notices (P.T.A.B. Mar. 26, 2025)
Patent Owner GODO KAISHA IP BRIDGE 1 hereby makes the following Mandatory Notices.
These Notices are timely filed within 21 days of service of the Petition for Inter Partes Review by Petitioner WESTERN DIGITAL
Postal Mail, Courier, or Hand Delivery:
A Power of Attorney from the Patent Owner GODO KAISHA IP BRIDGE 1 is being filed concurrently with these Mandatory Notices.
I certify that on March 26, 2025, a copy of the foregoing document, including any exhibits filed therewith, is being served via electronic mail, as previously consented to by Petitioner, upon the following: Michelle E. Armond Douglas R. Wilson Josepher Li Monica Arnold Yue Han
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1 Petition as filed: Petition as filed

Document IPR2025-00701, No. 1 Petition as filed - Petition as filed (P.T.A.B. Mar. 6, 2025)
None of the requirements of Claim 5[b] are inventive: Claim 5[b] recites that “J is a tunnel current density flowing through the barrier layer.” EX1011 at 10:18-19.
None -43- Western Digital v. Godo Kaisha IP Bridge IPR Petition – U.S. Patent No. 10,367,138 of these methods were identified as inventive or unexpectedly leading to higher- than-expected performance.
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2 Notice Power of Attorney: Notice Power of Attorney

Document IPR2025-00701, No. 2 Notice Power of Attorney - Notice Power of Attorney (P.T.A.B. Mar. 6, 2025)
Patent Owner.
Petitioner Western Digital Technologies, Inc. hereby appoints the following practitioners as its attorneys to transact all business before the Patent Trial and Appeal Board of the United States Patent and Trademark Office associated with the inter partes review of U.S. Patent Nos. 7,884,403; 8,319,263; 8,405,134; 9,123,463; 9,608,198; 10,367,138; 10,680,167; 11,737,372; and 11,968,909.
By: Taylor King Assistant General Counsel Western Digital Technologies, Inc. August 19, 2024
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1090 Exhibit: US Patent No 7,252,852 Parkin 852

Document IPR2025-00701, No. 1090 Exhibit - US Patent No 7,252,852 Parkin 852 (P.T.A.B. Mar. 6, 2025)
Inventor: Stuart Stephen Papworth Parkin, San Jose, CA (US) (73) Assignee: International Business Machines Corporation, Armonk, NY (US) Subject to any disclaimer, the term of this patent is extended or adjusted under 35 U.S.C. 154(b) by 54 days.
Once the interface structure is optimized, either by optimiz- ing the growth or by post-growth armealing, for sufficiently thickA12O3 turmel barriers which give rise to resistance-area (RA) products exceeding -100-500 Qµm 2 , TMR values 45 between 40 and 50% can be obtained for almost all of these ferromagnetic alloys.
Moreover, the perpen- dicular current geometry in MTJ read heads means that the sensor resistance increases as the area of the device is reduced for higher capacity disk drives.
US 7,252,852 Bl These studies show that the spin polarization of the tunnel current measured in this way can be simply related to the TMR close to zero bias voltage as first proposed by Juliere (M. Julliere, Phys.
Popova et al. also suggest that the modest TMR values they find, especially when compared to the theoretical predictions of Butler et al., may result from the formation of an FeO layer at the Fe/MgO interface during the deposition ofMgO on the lower Fe electrode.
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1089 Exhibit: Espacenet Translation of Japanese Patent No JP2000106462 “Kishi”

Document IPR2025-00701, No. 1089 Exhibit - Espacenet Translation of Japanese Patent No JP2000106462 “Kishi” (P.T.A.B. Mar. 6, 2025)
[0005] On the other hand, in the above-mentioned ferromagnetic tunnel junction, it has recently been revealed that a large magnetoresistive ratio can be obtained as compared with a GMR material such as a spin valve film.
, Ta/Pd, Al2 O3, amorphous alloy, etc., can be used as the underlayer to flatten the upper laminated structure and change the crystal growth, so that the exchange bias of the antiferromagnetic film/ferromagnetic layer interface is strong.
[0032] Specific constituent materials of the tunnel barrier layers 3, 12, and 14 include insulators (dielectrics) such as Al2O3, AlOx, SiO2, SiOx, AlN, NiO, CoO, MgO, and HfO2, FeSi, GeSb, and PbSe.
In addition, current-voltage characteristics are measured, and assuming that the voltage applied per layer is half, S and Φ are obtained using the Simmons equation, and S/(Φ)1 The relationship between the temperature dependence of the magnetoresistance ratio and S/(Φ) 1/2 can also be determined by calculating /2.
[0071] First, at the initial degree of vacuum of 2×10 −7 Torr, the above-mentioned laminated film was formed into a lower wiring shape with a width of 50 μm by using ordinary photolithography technology and ion milling
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1095 Exhibit: Library copy of Wang EX1055

Document IPR2025-00701, No. 1095 Exhibit - Library copy of Wang EX1055 (P.T.A.B. Mar. 6, 2025)
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